2012-06-22 New ECCDK Export Control FAQ
The area of export compliance is a truely complex field of expertise requiring many years of training and consultating with rules, laws and experts. It is not very difficult to break the rules, as many rules are not obvious at all. Further to that, many rules are written in such a way that they do not provide a clear answer as to what you can and cannot do – they may often be interpreted to such an extent that that even the appropriate authorities are in doubt, which often endd up with you getting the least favourable treatment. Having said that, it also needs to be said that the service level of export compliance authorities has increased in the more recent years.
You will never meet a single export with knowledge about all export compliance rules in that there are different rules from one country to another, and international or extraterritorial rules add a difficult layer on top of national rules. Therefore, collecting knowledge into a FAQ seems reasonable, and the first bits of knowledge from ECCDK are now published. An example:
Q: We are receiving visitors from abroad – should we be concerned about export controls?
Yes, if your facility holds controlled commodities or data. Foreign visitors originating from embargoed or sanctioned countries cannot be allowed access to commodities or data controlled for that particular country. Giving access corresponds to exporting to that country. If you are handling export controlled commodities or data, you may need a visitor control program, which requires approval of foreign visits, registration of visits, and possibly also escort of visitor. If you already have implemented a security program, such visitation procedures are easy to handle.
Find the ECCDK FAQ right here.